SEC Reminds Investment Advisers to Review Compliance Policies Annually


Norm Champ, Director, SEC Division of Investment Management, recently gave a speech where he reminded investment advisers to review compliance policies annually as required by SEC rules. He said “As you are no doubt aware, Rule 206(4)-7 requires advisers to adopt, implement and annually review compliance policies and procedures reasonably... Read More

Topics: Investment Advisers, Uncategorized

Dodd-Frank Whistleblower Claims Subject to Arbitration, Key Distinctions Between Dodd-Frank and Sarbanes-Oxley Whistleblower Protections


The below article by Sean Colligan was featured in the April issue of Stinson Leonard Street’s Business Torts Update, which focuses on recent developments affecting litigation of securities law, whistleblower, trade secret and non-compete claims. Two recent U.S. District Court decisions hold that whistleblower claims under the Dodd-Frank Act are subject to... Read More

Topics: Employment, Litigation, Public Companies and Securities, Uncategorized

Implementing the Minnesota Revised Uniform Limited Liability Company Act

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The Minnesota Revised Uniform Limited Liability Company Act (the “Revised Act”) has been adopted in Minnesota and will replace Minnesota’s current limited liability company (“LLC”) statute set forth in Chapter 322B of the Minnesota Statutes (the “Existing Statute”).  The Revised Act, which will be found in Chapter 322C of the... Read More

Topics: Uncategorized

SEC Announcements on Confidential Treatment Requests and Glossy Annual Reports


The SEC Division of Corporation Finance has recently posted two Division Announcements: As of April 9, 2014, in cases where the SEC staff has determined to grant a request for confidential treatment without providing comments, the staff will no longer separately notify the applicant in connection with issuing an order. ... Read More

Topics: Public Companies and Securities, Uncategorized